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of <h1>Article 28 of DTAA with Korea Limits Benefits for Tax Avoidance, Impacts Articles 10, 11, 12, 13, 22.</h1> Article 28 of the Double Tax Avoidance Agreement (DTAA) with Korea addresses the limitation of benefits. It ensures that the agreement does not restrict any anti-tax avoidance laws of a Contracting State. Individuals or entities cannot claim benefits if their arrangements primarily aim to avoid taxes under the agreement. Specifically, for Articles 10, 11, 12, 13, and 22, residents of a Contracting State are denied benefits if they are controlled by non-residents or if the primary purpose of transactions is to exploit these articles for tax advantages.
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